March 22, 2021

Manifesto for the protection of European Deltas

Within the European legal framework, there are several regulatory texts that, directly or indirectly, affect the conservation and management of deltas. However, the regulatory framework established by the European Union Directives is not sufficient to guarantee the physical protection of the deltas.

That is why we call on the European Commission to increase efforts to conserve and restore European deltas, especially within the framework of the Water Framework Directive and its implementation in the Member States.

85 MEPs and 59 associations, academic and research centres from across Europe have signed a manifesto in support of the protection of Europe’s deltas. CCB is one of the signatories.

Read the Manifesto here.

March 4, 2021

Rivers´regulation in Poland: open letter to the Polish Prime Minister Mateusz Morawiecki

Moratorium on rivers’ development is required in the implementation of any project financed by public money.

The reason for calling for a radical intervention by the Polish Prime Minister concerns the ill-adapted water management. The current state of the water management and the challenges of the national wealth: the natural river network in Poland, is a serious problem. Supporting the need to renegotiate the Water Act, quick and radical measures are necessary to prevent further devastation of rivers.

Therefore, we call for:

  • Water management in Poland should be performed by an institution responsible for the protection of the environment, natural resources, climate and forestry to implement modern descriptions of natural rivers (by care and shaping in the corridor of the development of natural channels). It is important to equip this institution with appropriate funds for the protection and maintenance of rivers, but also with the possibility of constituting an opinion on the methods of interference by all stakeholders in the water resources of river valleys.
  • Introduce a general moratorium on the development, deepening and damming rivers in Poland. Ban use of obsolete catalogues and guidelines drawn up before 1980, until the introduction of a regulation to define modern rules for river shaping with understanding the river morphology of channels and its environmental requirements.
  • Arranged a variable river basin management in Poland to restore the natural ecosystem services. Use natural retention potential to counteract the effects of climate change (in the context of drought and floods, while recovering the near-natural self-purification of basin systems to reduce the adverse effects of emissions from basin areas).

Read the full Moratorium here.


November 5, 2020

Joint NGO letter to EU Commission on Baltic proper harbour porpoise

In September 2020, together with NABU, WWF, Whale and Dolphin Conservation, Swedish Society for Nature Conservation and Danish Society for Nature Conservation, we sent a letter to Virginijus Sinkevičius, EU Commissioner for Environment, Ocean and Fisheries, on the protection of the Baltic proper harbour porpoise.

In the letter, we expressed our concern about the low level of ambition in the current negotiations within BALTFISH to develop a Joint Recommendation [1]. The current BALTFISH proposal for measures does not meet the legal requirements to protect this population, and is missing key components of the ICES advice [2].

Read the full NGO letter and Commissioner Sinkevičius´s reply.

September 11, 2020

CCB welcomes the release from custody of our colleague Iryna Sukhy and expresses strong support to Belarusian civil society organizations

Coalition Clean Baltic – CCB welcomes the release from custody of our long-time colleague and environmental activist Iryna Sukhy and expresses strong support and solidarity with the peaceful actions of Belarusian civil society organizations.

Iryna Sukhy, the co-founder of the NGO Ecohome was unjustifiably and unlawfully detained and convicted last Sunday, 6 September in Belarus. Regretfully, her situation became yet another and truly unprecedented case of blocking access to justice, following Iryna’s strong stand and position on numerous environmental deficiencies in Belarus. Harassment of activists working in non-profit environmental organizations is totally unacceptable and CCB’s protest against such measures is not linked to a political situation in a country but about the targeting of people that dedicate their lives to protecting our environment.

At the same time, we would like to remind that environmental protection in the Baltic Sea Region has always being the uniting element between the countries, irrespective of their political systems and ruling ideology, recognizing no borders.

We believe that violence and confrontation, leads only to further escalation of a conflict and splitting up the Belarusian society, and therefore call upon all parties for a dialogue to resolve the crisis.

We support the efforts of CCB’s Belarusian members and partners in promoting such a dialogue through strengthened civil society engagement, public participation, awareness raising and capacity building.

*Coalition Clean Baltic is a network of 24 environmental NGOs from 11 Baltic Sea Region countries, striving to protect the environment and natural resources of the Baltic Sea for present and future generations.

 On behalf of the CCB
Aija Caune,
CCB Chairlady

Download the full statement here.


September 5, 2019

CCB joined the Ocean Call for G7

We have joined and signed the Ocean Call, which carries the voice and the commitments of more than 50 organizations mobilized for the ocean alongside Surfrider Foundation Europe.

Following the G7 Summit, the Ocean Call will also be staged at the United Nations Climate Change Summit in New York in September, at the COP 25 in Chile in December and finally at the COP 15 on Biodiversity in China in 2020.

Read the full declaration here.

March 6, 2019

Real actions, not ´realistic´ wishes – a recipe for an updated Baltic Sea Action plan

On 6-7 March high-level representatives met at the 40th Meeting of the Helsinki Commission. On this occasion, CCB was grateful to share the concerns of civil society organizations and almost a million individual members of CCB´s network around the Baltic Sea. Our concerns were (and are) connected with continuous and increasing violations of the fundamental principles and provisions of the Helsinki Convention:

  • Precautionary principle and science-based management;
  • Transparency, trust and sharing information to minimize transboundary impacts;
  • Joint measures for reaching joint goals, instead of prioritising actions of “overriding national interest”.

Read the full CCB´s statement here.


December 7, 2018

A joint NGO proposal to EU Ministers regarding European eel

On December 17th and 18th 2018 the EU Fisheries Council (AGRIFISH) will decide on fishing opportunities for 2019 and will address measures for critically endangered European eel. ICES has yet again repeated their advice that: “all anthropogenic impacts (e.g. caused by recreational and commercial fishing on all stages, hydropower, pumping stations, and pollution) that decrease production and escapement of silver eels should be reduced to – or kept as close to – zero as possible in 2019” [ICES Advice 7th November 2018].

We call upon – together with The Fisheries Secretariat, Swedish Society for Nature Conservation, Our Fish, Seas at Risk and WWF – the EU Commission and Member States to act accordingly in light of this advice, the same advice ICES has given for over 15 years.

Read the full letter here.

November 28, 2018

WWF Sweden, SSNC and CCB call upon Swedish government to stop fishing for eels

In light of ICES advice, eNGOs urge to a total ban for all fishing of eels in all waters – but welcome the first step regarding fishing of eels over twelve centimetres, decided by the EU Fisheries Ministers last year, which will apply for three consecutive months between 1 September 2018 – 31 January 2019.

We therefore ask that Sweden take lead and push for a phasing out of the eel fishery at coming December meeting of AGRIFISH across the entire EU, on all sizes of eel and that recreational fishing is stopped.

The full letter in Swedish is available here.

September 24, 2018

Joint NGO recommendations on Baltic Sea fishing opportunities for 2019

In October 2018, EU fisheries ministers are scheduled to agree on fishing opportunities in the Baltic Sea for 2019. The following text outlines the joint NGO recommendations on Baltic Sea fishing
opportunities for 2019 in the context of EU fisheries legislation, scientific advice on catch limits and the sharing of stocks with third countries.

Read the NGOs proposal here.

August 13, 2018

50 NGOs call on the International Seabed Authority to reconsider the need for deep sea mining

As the International Seabed Authority (ISA) gathers in Jamaica (24th session, July 2018), environmental organisations are calling on governments to wake up to the irreversible harm that deep sea mining will inflict, not only to marine ecosystems but also to global efforts to transition to a sustainable economy.

In a joint statement to the ISA, 50 organisations, including CCB, Greenpeace and Seas At Risk, warn of significant loss of biodiversity if the world’s seabeds are opened up to mining.

Read the full statement here.

June 28, 2018

CCB position on grey seals in the Baltic Sea

In line with Art. 14-16 of the EU Habitats Directive, hunt on specific seal populations can be allowed, under strict conditions, provided that the conservation status of the population is monitored to ensure that it is maintained at a favourable conservation status. Based on this, grey seal hunt is only allowed in Sweden (600 animals), Finland(1050), Åland (450), Estonia (37) and Denmark (only Bornholm, 40).

However within 2017-2018 several incidents of suspected deliberate illegal killing of grey seals were observed in Lithuania (26), Germany (23-27, Rugen), Finland (2, Hamina), Poland (>10, Eastern Pomerania) and Russia (3, Kaliningrad).

Read our full position here.

June 13, 2018

CCB supports the joint call on the European anti-fraud office to open a formal investigation about electric fishing

CCB has signed the joint formal request, lead by the Bloom Association, to the European Anti Freud Office (known as OLAF from the French “Office européen de lutte antifraude”) to conduct an investigation into whether fraud has occurred in relation to the Dutch electric trawl fishery.

Electric fishing is one of the worst fishing practice and it MUST be banned in Europe!

Read the full PR here.

June 11, 2018

CCB position on the Sweden approval for the Nord Stream II

On 7 June 2018, the Swedish Government has granted a permit to the Nord Stream 2 AG for laying two natural gas pipelines on the continental shelf within the Swedish economic zone in the Baltic Sea. The permit contains number of conditions that the company has to comply with, as outlined in the attached unofficial translation (see full version of the permit in Swedish here)

At the same time, the Government has made it clear that Sweden has a critical attitude towards the Nord Stream 2 project, as it poses risks i.a. against the objectives of the EU Energy Union and does not comply with current EU legislation. Read more in the press-release by the Swedish Government.

Despite the released permit that only applies to the construction works within Swedish EEZ, the Coalition Clean Baltic maintains its position (being repeatedly brought to the attention of EC and HELCOM)  that the Nord Stream 2 is highly controversial from environmental point of view project.

Read the full position here.

March 5, 2018

Civil Society Declaration on Ecosystem Health of the Baltic Sea

As representatives of the civil society in the Baltic region, we have developed our own initiative declaration as input to the HELCOM ministerial meeting in Brussels 6th of March. This is a declaration created by CCB as a statement, outlining the preferences and clear needs with the current state of the Baltic Sea. This statement has been shared with the contracting parties in HELCOM and is a part of the background documents to the Ministerial Meeting .

Read the full document here: Civil Society Declaration on Ecosystem Health of the Baltic Sea Final

March 5, 2018

Joint NGO letter to ministers about HELCOM BSAP

A joint NGO letter from CCB, Oceana and WWF to the minsters of environment concerning the progress towards BSAP goals in 2021. This letter was sent as part of the Ministerial meeting in HELCOM, 6th of March 2018:  Joint Letter to ministers on BSAP WWF Oceana CCB


December 14, 2017

CCB’s Reaction to Council Decision on Eel December 2017

CCB’s reaction to the December EU Fisheries Council decision on eel

The critically endangered eel was sidelined yet again at the EU Fisheries Council. The Ministers of EU Member States only managed to agree on a short fishery closure period of their own choice. The decision represents a remarkable disregard of MSY and CFP rules and the Ministers fought to keep fishing open on an endangered species in an unprecedented way. The small sliver of hope is in the signed commitment to do more for eel and CCB will now turn attention to the Minsters demanding them to be true to their word. CCB acknowledges and thank for the work done by the Commission and Commissioner Vella for standing up for the rules and the protection of eels.

The matter of increased protection for the critically endangered eel was discussed over two days at the Fisheries Minsters Council meeting in Brussels 11-12th of December and a final outcome was presented in the early hours of December 13th. The Commission had proposed a total ban for all eel fishing on adult eels in the marine waters of the EU and presented a paper of commitment for the Member States to support and agree to step up protection measures in all waters.

The result of the discussions is a huge disappointment. Despite the fact that science has called for all mortality as close to zero as possible and the downward trend in eel recruitment is continuing, member states only accepted a short migration closure period for three months,  however it is up to each country to decide when in the period from 1st of September to 31st of January next year. Firstly, this period is not at all well timed with actual migration and second, Member states can for example chose winter months November to January when virtually no fishing takes place anyway.

Several member states fiercely defended a fishery on endangered eels and refused to close the marine fishery. By doing so, the Member States openly disregard the rules of the sustainable fishing levels, undermined the possibilities of reaching good environmental status and  the goals of the Convention on Biodiversity (CBD) as well as the UN sustainable development goals. By defending a fishery on a critically endangered species for example based on traditions, the EU member states also aligned themselves with nations that proclaim a right to hunt for whales.

It seems as if the status of the eel cannot get bad enough for any Member State to react. In addition, their arguments and actions clearly gives the impression that the Ministers thinks the best way to protect an endangered species is to fish for it and eat it. CCB must underline that it is neither possible nor valid to compare eel with any other fish species, because of the eel’s long life cycle and terrible status. It is not acceptable to talk about sustainable use of a fish resource when recruitment has all but collapsed and yet a main argument presented by several Member States is: we have done enough already.

The hopeful part of the outcome is a declaration supported by the Minsters on next steps and needed actions. Also this text was opposed in the first draft version but there remains some important statements:

  • All acknowledge that the stock of European eel is in critical condition
  • Urgent action is needed to ensure the recovery of the stock across its natural range and that measures that further reduce eel mortality caused by human influences during all eel life stages need to be in place as from 2018
  • Supporting that the Commission will launch an external evaluation of the Eel Regulation early 2018 with a view to its possible revision
  • More emphasis on inland measures: fisheries, recreational fisheries, hindrances and habitats

CCB is committed to improving the chances for the eel recovery and we now demand from the Member States to do more and we can only repeat the message sent in a letter to all Minsters before the Council meeting, what more are you willing to do now?

More information:

Fisheries Council outcomes, December 12th

The list of participants at Council to hold responsible


November 17, 2017

HCWH Europe’s Declaration on Pharmaceuticals in the Environment

20 Organisations sign declaration expressing serious concern about pharmaceuticals in the environment in the EU

Due to World Antibiotic Awareness Week,  Health Care Without Harm (HCWH) is releasing this declaration expressing serious concern about pharmaceuticals in the environment in the EU.
The consortium of organisations wrote to the Commissioner to highlight the importance of introducing ambitious legislation in the upcoming Strategic Approach to Pharmaceuticals in the Environment (due to be released in early 2018). The Declaration also highlights the unintended consequences of the release of increasing amounts of pharmaceuticals into the environment on both human and environmental health.

We strongly believe that the following steps are necessary to address the problems posed by pharmaceuticals in the environment and should therefore be incorporated into the strategic approach:
1. Minimise the entry of pharmaceuticals into the environment throughout their life cycle.
2. Ensure zero discharge of pharmaceuticals in the environment during the entire production process.
3. Increase transparency and ensure consistently high standards along the entire pharmaceutical supply chain, including in countries outside the EU where the majority of pharmaceutical manufacturing occurs. This could be achieved by incorporating environmental criteria in the Good Manufacturing Practice (GMP) framework.
4. Extended producer responsibility should apply to the pharmaceutical industry – producers should be accountable for pharmaceutical waste throughout their life cycle.
5. Assess the potential environmental risks of all human and veterinary pharmaceuticals and ensure regular environmental review of authorised pharmaceuticals based on current scientific knowledge.
6. Encourage green procurement as a means of switching to pharmaceuticals with a lower environmental impact.
7. Promote the rational use of pharmaceuticals and education and awareness-raising campaigns about pharmaceuticals and their environmental impact.
8. Improve municipal wastewater treatment facilities in order to prevent environmental pollution caused by excreted pharmaceuticals.
9. Establish collection and take-back schemes, discourage the inappropriate disposal of unwanted pharmaceuticals in the home, and encourage awareness-raising and education programmes to dispose of unused pharmaceuticals safely.
10. Introduce comprehensive legislation to reduce the impact of pharmaceuticals in the environment.
11. Establish a procedure to define threshold values for single and mixture pharmaceutical residues in water bodies.
12. Ensure reduced discharge of pharmaceuticals from animal livestock holdings by promoting husbandry practices that foster animal health and prevent prophylactic antibiotics-use in veterinary medicine.

We call on the European Commission to consider our position on this issue and take immediate action to protect human and environmental health.

See full Statement in pdf

July 21, 2017

CCB requires that EIA on Nord Stream 2 Project addresses holistic and cumulative impacts on the Baltic Sea ecosystem

Uppsala/Stralsund, 21.07.2017

Statement at the public hearings on the Nord Stream II Project

21.07.2017, Stralsund, Germany

On behalf of the Coalition Clean Baltic, an NGO network of 19 grass-root environmental NGOs around the Baltic Sea, including BUND – Friends of the Earth Germany, altogether representing over 850 thousand Baltic catchment residents, I would like to give couple of reflections on the proposed Nord Stream 2 Project EIA in transboundary context. As we represent environmentally-concerned citizens of both Parties of origin and affected parties of the proposed project, CCB is honoured to represent their voice.

As stated in the Guidance on the practical application of the Espoo Convention, in most cases the Convention is applied between neighbouring Parties. However it is also noted that the Convention does not only apply to transboundary impacts between neighbouring Parties but also to long range transboundary impacts. Activities that can make long-range impacts in transboundary context include activities with air pollutants or water pollutants, activities potentially affecting migrating species and activities with linkages to climate change.

And in this case it applies equally to all Parties of Origin, be it not only Russia and Germany, but also Finland Sweden and Denmark. As the primary cause of the impact is not a construction and maintenance, but the very fact of laying the pipeline across the Baltic Sea.

Saying that we would like to raise the attention to couple of such transboundary impacts and draw the attention of Germany as one of the Parties of origin on the need to address those impacts.

Not to dwell in detail on the climate change related impacts, we would like to reflect that a common position of Baltic environmental NGOs is that NS2 Project is in direct contradiction with EU Paris COP goals of reducing greenhouse gas emissions by 80-95% by 2050, by replacing fossil fuels with renewable energy sources. And we have already notified the European Commission of this fact.

However, we would like to touch upon critical nature values of the Baltic-wide importance that are threatened by the proposed project.

First, about migratory, vulnerable and endangered species.

One of the reasons for designating new Marine Protected Area in the Swedish EEZ, south of Gotland, was that the protection status of the Baltic harbour porpoise was determined as unacceptably poor. It was pointed to Sweden by the EC in the assessment of implementation of the Habitat’s Directive. It was also backed by the new knowledge that became available quite recently through the SAMBAH Project, providing a reliable and scientifically confident estimate that number of those small whales in the Baltic Sea is not more than 500 and each year we lose some of them due to human-induced mortality, e.g. fisheries. At this level the population of harbour porpoise is so critical that loosing even single animal that could breed and bring offspring is a huge loss. Therefore, the Swedish Government has put in place a protected area at Mid-Sea banks and develops a management plan to limit various human activities within its boundaries, including fisheries, shipping, deep sea mining or laying infrastructure. In that sense, adding yet another disturbing factor in the area that is crucial for mating, breeding and nursing of the harbour porpoise throughout almost the whole year is certainly a significant negative impact that has to be minimised, if not prevented. With this respect we are seriously concerned with the NS2 estimation of level of underwater noise produced and respective impacts it may cause while trenching and pipe-laying during the proposed project. With the knowledge we have, backed by science including HELCOM experts on underwater noise, we firmly require that should the project be permitted to commence, trenching and pipe-laying should be limited to the period from December to March. This consolidated NGOs position was also reflected at the public hearings in Sweden, where an option of shifting the route off the limits of the protected area was already lifted up.

The same goes without saying with regards to endangered ringed seal population in the Gulf of Finland that is already quite affected by similar human factors as harbour porpoise, and in addition – by climate change. The ammunition clearance and actual pipe-laying process in the vicinity of ringed seal haulouts and reproduction areas is a significant impact that cannot be neglected. So far, neither the ammunition issue nor the proposed routeing of the pipeline have been adequately responding to the associated environmental risks to ringed seals. This also became obvious and was highlighted at the public hearings in Estonia and Finland.

Secondly, about critical habitats of international importance

The proposed route that has been presented by the Nord Stream 2 AG as a part of Espoo EIA international consultations documentation is also a significant concern in terms of other common Baltic nature values. We would particularly like to point here to the landfall part in Russia, in the Gulf Finland. The route proposed by the company as the best from environmental point of view and hence included in the Espoo documents as the only suitable alternative is simply not based on the law. It suggests to cross Kurgalskiy Peninsula, the nature protected area of dual international importance that is designated as a wetland of international importance under Ramsar Convention and a Baltic MPA under Helsinki Convention. Irrespective that none of the Conventions prohibits such human activities to be performed in those areas, any changes to the protection status should be duly justified, while simple commercial interest of saving money for a shorter route could not be considered enough justification. Moreover, current legal status of this protected area in Russia simply prohibits any construction works within its limits, not even saying about wiping out massive land area with up to 80 m wide trench. Really worrisome is the fact that according to our knowledge the efforts are undertaken to change the limits of the protected area to allow such activities to be carried out.

To make you a snapshot of the prospected impact, if such a development would be allowed, we would like to mention that the proposed landfall area in Russia is well known in the eastern part of the Gulf of Finland as the richest in terms of biodiversity with over 100 species of fauna and flora being redlisted as regional, national and Baltic-wide endangered and rare species. Habitats are represented by a mixture of pristine old-growth forests, bogs and dunes. In addition, it is an area that has been traditionally populated by indigenous Finno-Ugric people, being very much connected to nature and its values. Nature is a part of their traditional way of living, they are dependent on careful harvesting of nature resources. So, severe interference and impact that the NS2 Project would bring to the area is simply incomprehensible. It will be a devastating loss to natural, cultural, historic and social values that can hardly be avoided, minimised or compensated. It was pointed out in numerous inputs at the recent public hearings in Russia.

By the way the Russian national EIA process should be formally launched today, where we expect yet another round of discussions with the developer of the project. In that sense, the international attention to the issues we raised is highly relevant for the outcome of this whole process.

We believe that all Parties of Origin should realise the level of impacts that are not limited to adjacent areas only, but are of Baltic-wide importance, and that they bear full responsibility for those impacts by permitting the project in the way it is proposed now.

See full Statement in pdf here

February 28, 2017

To reach the SDGs globally the Baltic-wide actions need to be implemented first!

logo_2rToday, high-level representatives of the HELCOM Contracting Parties will meet in Helsinki to discuss how the Baltic Sea Region can contribute to the global goals on the conservation and sustainable use of the oceans, seas and marine resources by 2030. Actions related to eutrophication, marine litter and climate change will be given special focus in the discussions.

On behalf of environmentally concerned citizens of the Baltic Sea catchment, Coalition Clean Baltic would like to share some input to this work and bring to the attention of regional decision-makers the urgent needs to be addressed in order to reach the Sustainable Development Goals, (SDGs) and, even more importantly, to save the Baltic Sea from further deterioration.

Read the full statement here.







October 4, 2016

Joint position of environmental NGOs on internal loading in the Baltic Sea


WWF, Sweden




04 October 2016, Uppsala/Stockholm

Joint position of environmental NGOs on internal loading in the Baltic Sea

Environmental Ministers and High-Level representatives from HELCOM Contracting Parties at their meeting in Copenhagen in 2013, inter alia

  • agreed to fully implement the 2007 Baltic Sea Action Plan by 2021 and to step up efforts for further strengthened implementation of the BSAP
  • acknowledged that environmental deterioration such as oxygen depletion is increasingly affecting marine life by e.g. accelerating eutrophication through increasing the internal loading;
  • supported development of environmentally sound approaches to remove the nutrients before they enter inland waters and the sea, and to address the internal loading, in coastal areas and semi-enclosed lagoons, as well as in the open sea;

The issue of internal loading was brought up to HELCOM’s agenda with the assumption that most of the reductions on land (both at point and diffuse sources) have been already achieved, e.g. through accomplishment of efficient sewage treatment and excess usage of fertilizer and manure in agriculture being gradually eliminated. Hence, according to the proponents, very limited, costly and constantly diminishing reductions can be achieved using conventional land-based approach, and thus interest on innovative sea-based measures that should be investigated and applied have gained traction.

NGOs strongly believe that the real reason for promoting alternative, sea-based solutions to the eutrophication problem might be tightly connected with observed poor implementation of BSAP MAI/CART commitments and lack of will to enforce stricter HELCOM requirements at national level in comparison to EU law, by some Contracting Parties/EU Member States. This recently became even more evident with several Contracting Parties questioning the MAI/CART scheme that was jointly agreed in 2007 and reviewed in 2013. Another possible reason could be the need to develop and implement ‘novel’ measures, not yet being used in current EU policies e.g. WFD or Nitrates Directive process, in order to be able to feed those into Programmes of Measures under the MSFD.

Meanwhile, cost-efficiency of already applied measures in terms of delivering good environmental status for the Baltic Sea with regards to eutrophication has been very poorly assessed – both at national or HELCOM level. So far only potential economic benefits stemming from implementation of the HELCOM BSAP measures have been evaluated. On the contrary the EU financial support mechanisms in many cases, e.g. in agriculture, cause continued high inputs of nutrients with minor consideration of environmental objectives for the marine environment.

Our understanding is strongly supported by the findings of the recent EU Court of Auditors’ report “Combating eutrophication in the Baltic Sea: further and more effective action needed” (2016), echoed by the EU Council Conclusions on the ECA’s Report, which reflected the following:

  • within 2007-2013 the EU contribution to waste water collection and treatment projects in the BSR was 4.6 billion euro from ERDF/CF, while rural development measures, including water protection measures amounted to 9.9 billion euro from EAFRD.
  • Member States’ plans for achieving HELCOM nutrient reduction targets are lacking ambition as they do not go beyond statutory EU requirements, that do not suite the Baltic-specific needs; those plans are often delayed and vary in level of enforcement, as well as based on insufficient information and lack progress monitoring; moreover HELCOM requirements on sewage treatment and agro-environment measures are not in full incorporated into national legislation in most of the Contracting Parties.
  • None of the Baltic EU MS have reached good ecological status of their surface and ground waters by 2015, as originally set under the WFD and hence reaching in time Good Environmental Status under the EU MSFD is also very questionable, again partly due to lacking coordination with the objectives and activities of the existing regional sea conventions (HELCOM)

On February 12, 2015 the seminar “Sea-based measures to reduce the effects of eutrophication” was arranged by Sweden’s Ministry of Environment, Baltic Sea Centre and Swedish Agency for Marine and Water Management with the aim to review nine pilot projects and in light of these, to discuss opportunities and challenges associated with sea-based measures to reduce internal loading. During the seminar it was pointed out by many participants that the Baltic Sea ecosystem is fragile and there is a lack of knowledge about how the flora and fauna will react to these types of substantial human manipulations. Also the risks and uncertainties increase for the ecosystem when the measures applied go from small scale at the coastal level to large scale on the open seas. However, the concluding panel agreed that some offshore activities in the future might be complementary to current land-based measures to speed up the recovery of the Baltic Sea.

Putting it candidly, the internal nutrient load in the Baltic Sea means a recirculation of “old sins”, hence it is a consequence and not a cause of eutrophication. Despite pilot attempts, scientific knowledge is still lacking and vast uncertainty remains about the effectiveness of measures to reduce the internal load, especially for large-scale Baltic Sea wide application. Furthermore, the total costs of the proposed measures have not been calculated, neither any estimates of effectiveness and environmental consequences of proposed measures on the open Baltic Sea ecosystem have been produced. As currently the anoxic “dead” bottom zones extend to several national EEZs and cover an area comparable to twice the size of Denmark, the question remains who should pay for the needed EIA and investments for technical solutions addressing open sea eutrophication.

Despite no formal discussion has been held on internal load within HELCOM since the seminar, HELCOM HOD 50-2016 requested to include issues on internal load into the agenda of PRESSURE 5-2016.

Based on the above and to express the joint Baltic environmental NGOs position on the discussion, we would like to draw the attention to several important points on this issue to reflect upon:

  1. Internal load is not a cause of eutrophication, but it is a consequence of numerous years of mismanagement of nutrient inputs from the Baltic Sea catchment. According to the Baltic Eye’s policy brief “The internal phosphorus load – recycles old sins” (October 2016), the accumulated load of nutrients in the catchment is about 20 times higher than estimated load bound in bottom sediments. Hence, nutrient sources in the catchment will still need to be addressed as being the root cause of phosphorus accumulation on the sea floor.
  2. There is no evidence that the Contracting Parties have taken and implemented all relevant measures to reduce eutrophication, as agreed in HELCOM BSAP – especially from land-based sources (stricter sewage treatment and fertiliser application, nutrient recycling, etc.) and as agreed in Article 6 and Annex III of the Helsinki Convention (1992).
  3. Although positive effects of reduced land-based input could be seen in some coastal areas, there is still a need for further improvement. Measures for continued reduced supply and a more resource-efficient use of nitrogen and phosphorus have effect and are of great importance and should be a priority, not least in order to reduce eutrophication in lakes, rivers and coastal waters in the Baltic Sea Region, in meeting the WFD and MSFD requirements.
  4. Proposed sea-based measures to address internal loading have not proven to be (a) effective, (b) cost-efficient, (c) polluter-specific and (d) harmless in application at a larger scale and in longer-term perspective, hence violating two fundamental principles of the Helsinki Convention, namely precautionary and polluter-pays principle.
  5. Very few end-of-pipe solutions have appeared to be more efficient than source reduction measures. Without curbing nutrient pollution sources we will not be able to cease eutrophication cause (point and diffuse inputs) and hence tackle the consequences at sea (anoxic bottoms, internal loading).
  6. External nutrient reduction before entering the sea is the only truly effective long-term strategy to combat eutrophication. Therefore, we call upon the Governments of the Contracting Parties to follow their commitments under the HELCOM BSAP and demonstrate it with real actions, i.a. finally endorsing Country Allocated Reduction Targets by all the Contracting Parties and implementing nutrient reduction measures stipulated by the Helsinki Convention (1992) and its Annexes.
May 12, 2016

Ministers: take action and uphold your responsibilities on marine protection

CCB has joined a group of NGOs  (Greenpeace, Oceana, WWF, Swedish and Danish Societies for Nature conservation, Swedish and Danish Anglers Associations, Living Sea and Fisheries Secretariat) and written an open letter to the ministers in Denmark and Sweden asking them to uphold the existing closed areas in the Kattegatt. The area has been closed to fishing since 2009 and may represent on of the few productive fishing areas in EU that has not been trawled at all the past 7 years.

The joint NGO position is that the area must be made a permanent closed area not only to protect fish reproduction and weak fish stocks but also because of natural values existing in the area. Following the closure in 2009, the recovery of the bottom in the area is remarkable and to protect the area permanently suits well with EU and Member states ambitions under Marine Strategy Framework Directive (MSFD) implementation. In fact the opposite, to not protect it, is hard to argue for or even consider due to the uniqueness of such a trawl free area. Opening up the area for active fishing and especially towed gear such as trawls is going from an clearly improved or even good environmental status (GES) towards not meeting the GES objective. That is a breach of the objectives of not only MSFD but also Common Fisheries Policy (CFP).

The full letter can be read here (in Swedish): Brev Kattegatt final svenska



Scientific statement: the area closed for fishing since 2009 has had clear positive effects and should stay in place. Read (in Swedish) http://www.gp.se/nyheter/v%C3%A4stsverige/stoppet-gav-effekt-torskbest%C3%A5ndet-v%C3%A4xer-1.115701

Swedish Scientific evaluation of the area (in English): http://www.slu.se/Documents/externwebben/akvatiska-resurser/publikationer/PM-Rapporter/Summary_Evaluation_of_Closed_Areas_in_Kattegat.pdf

STECF evaluation of the effects of the closed area (in English):https://stecf.jrc.ec.europa.eu/c/document_library/get_file?p_l_id=53314&folderId=133326&name=DLFE-12704.pdf


March 11, 2016

Statement at the 37th Meeting of the Helsinki Commission, 10-11 March 2016

Once again, we would like to share with you the concerns of civil society organizations and over 800,000 individual members of CCB’s network around the Baltic Sea.

Read Statement here: CCB_statement_HELCOM37_2016

February 15, 2016

Update of information regarding anthropogenic threats to Kurgalskiy Nature Reserve, Leningrad Oblast, Russia

CCB expressed its concerns regarding potential threats of industrial and urban developments in the vicinity of Kurgalsky Peninsula and Nature Reserve, the site of international importance, both listed as HELCOM MPA (#166) and the Ramsar Convention wetland (#690) at HELCOM HOD 49-2015

Read statement here: 7-2 Update of information regarding anthropogenic threats to Kurgalskiy Nature Reservey_CCB

February 15, 2016

Information by Greenpeace Russia about alarming situation at Krasny Bor hazardous waste landfill in Leningrad Oblast, Russia

Based on information received from Greenpeace Russia, CCB would like to raise attention of HELCOM Contracting Parties and Observer Organizations to the alarming situation with Krasny Bor hazardous waste landfill in Leningrad Oblast, nearby St.Petersburg.

Read Statement here: 7-1 Information by Greenpeace Russia about alarming situation at Krasny Bor hazardous waste landfill_CCB


December 11, 2015

CCBs joint statement on sustainable aquaculture – update 2015

CCB made already in 2014 a joint statement, underlining the important steps needed for a sustainable aquaculture sector in the Baltic Sea catchment. This statement has now been updated with a clearer stance on what we as an NGO group can support and that we do not consider open cage farms in the Baltic an option at all. Furthermore, in light of several pilot projects and research studies on compensatory measures, we do not consider such compensatory measures acceptable as arguments for allowing further development of open cage systems since they are neither economically viable nor actually compensate in a sufficient way. CCB considers closed re-circulatory land-based system (RAS) as best available technology (BAT) and that any and all public money to support a growth in the sector should only be used for BAT. Other land based systems such as ponds etc with species not requiring feed input or that does not produce nutrient run off can also be considered. This statement has also been translated into Polish and Lithuanian.

Read the statement here: CCB Sustainable Aquaculture update 2015 final

December 1, 2015

CCB statement on the conservation of the Baltic Sea harbour porpoise

These are CCB proposals for action for the conservation of the Baltic Sea harbour porpoise population. These actions are necessary for all EU Member States to fulfill the demands on monitoring programs and programs of measures under the MSFD, and to meet the requirements of the Habitat Directive and the HELCOM BSAP.

 Read the statement here: CCB_statement_on_porpoise_to_fulfill_MSFD_and_HELCOM_2015

November 19, 2015

Pending issues from HELCOM STATE & CONSERVATION 3-2015

With reference to the Terms of Reference of the HELCOM STATE & CONSERVATION Group, Coalition Clean Baltic submitted the following two information documents to the third Meeting of the Group:

  • (7J-4) Proposal for actions to save European eel in the Baltic Sea
  •  (7J-5) Physical loss and damage to the sea floor marine sediment extraction in the Baltic Sea

Read statement here: 4-19 Pending issues from State and Conservation 3-2015_CCB

November 19, 2015

Call for HELCOM action regarding Baltic MPAs within Russian part of the Gulf of Finland

In early September 2015, Coalition Clean Baltic approached Russian federal, regional and municipal authorities, as well as HELCOM, with a call for urgent action regarding the situation around one of the HELCOM Baltic MPAs and Ramsar sites in the Russian part of the Gulf of Finland, namely Kurgalsky Natural Reserve.

Read statement here: 4-18 Call for HELCOM action regarding Baltic MPAs within Russian part of the Gulf of Finland

November 19, 2015

Funding the EU MSFD Programs of Measures

A crucial part of the coherent implementation of the BSAP and the EU MSFD is the commitment to fund the needed measures to reach the GES targets. CCB is becoming concerned that several CPs being also EU MS have argued at different occasions, including the IG PoM and EU MSCG, that funding is a major problem for implementing the MSFD PoMs.  For a number of reasons CCB considers these claims unjustified.

Read statement here: 4-17 Funding the EU MSFD Programs of Measures_CCB

November 11, 2015

Proposal for actions to save European eel in the Baltic Sea

European Eel (Anguilla anguilla) is listed as critically endangered (one step away from extinct in the wild). The EU in 2007 jointly decided on a management plan for the recovery of the eel stock. The Member States are required to take measures to secure that 40% of adult eels reach the sea for migration to spawning grounds. It is the Member States own responsibility to take relevant measures, and the Commission reviewed the measures so far.

Read statement here: 7J-4 Proposal for actions to save European eel in the Baltic Sea


November 2, 2015

Physical loss and damage to the sea floor: marine sediment extraction in the Baltic Sea

HELCOM’s Initial Holistic Assessment of Ecosystem Health of the Baltic Sea (BSEP122) considers dredging and marine sediment extraction as pressures, which can have large impacts on local marine environments. Such impacts include smothering of benthic organisms, abrasion of the sea bottom, as well as increased siltation and resuspension of contaminated bottom sediments caused by dredging/extraction activities. Scientific studies, underwater observations and hydrographic surveys have shown that impacted bottom sites can take decades to recover, if at all do so.

Read statement here: 7J-5 Physical loss and damage to the sea floor marine sediment extraction in the Baltic Sea

November 2, 2015

Call for action regarding the situation around Kronshtadskaya Kolonia Reserve, Russia

The Coalition Clean Baltic would like to raise the attention of HELCOM State & Conservation Group experts and call for urgent HELCOM’s action regarding the situation around Bronka multifunctional marine cargo complex and neighbor nature reserve “Kronshtadskaya Kolonia”, located in St.Petersburg, Russian Federation.

Read statement here: 3N-6 Call for action regarding the situation around Kronshtadskaya Kolonia Reserve, Russia

October 23, 2015

Call for action regarding the alarming situation around Kurgalskiy Nature Reserve, Russia

The Coalition Clean Baltic would like to raise the attention of HELCOM STATE & CONSERVATION Group experts and call for urgent HELCOM’s action regarding the alarming situation being reported around Kurgalskiy State (Regional) Nature Reserve, located in Leningrad Oblast of the Russian Federation.

Read statement here: 3N-4Cover CCB letter on Kurgalskiy

October 20, 2015

Comments on final draft of the BAT reference document for the Intensive Rearing of Poultry or Pigs

Comments on final draft of the BAT reference document for the Intensive Rearing of Poultry or Pigs (IRPP BREF). Proposal for some rewording in the BAT conclusions 30 to 34.

Read here.


September 18, 2015

Open letter addressing Russian authorities and HELCOM

Open letter addressing Russian authorities and HELCOM with regards to an alarming situation around Kurgalskiy Nature Reserve at the coastline of the Gulf of Finland.

The letter addresses the situation, which mainly concerns conflicts between nature protection goals, large infrastructure projects and urban planning of the coastal area in the vicinity of the Kurgalskiy State Nature Reserve. The situation requires urgent action to prevent damage to natural amenities of this Protected Area and save it as the only MPA within Russian part of the Baltic Sea that covers both land and sea area.

Read the letter here. Note: the letter is both in English and Russian.

August 19, 2015

Time to Stop Eel fishing

CCB together with 28 environmental organizations has sent this letter to the EU Commission demanding that all eel fishing in Europe should stop and that other needed action to halt the human induced eel mortality until the stock has recovered must be put in place. Read the letter here

June 3, 2015

Proposals for scope of the review and updating of part II Annex III (Prevention of pollution from agriculture) of the Helsinki Convention

HELCOM HOD 47-2015 requested the Agri group to develop a proposal for the review process of part II of Annex III for the consideration by the Heads of Delegation. Once the scope of the review has been decided on by HOD, the revision process could start. The Meeting invited the Contracting Parties to consider co/leading the review/revision work.

Read statement here: 3-25 Proposals for scope of review of part II Annex III of Helsinki Convention

April 17, 2015

Statement on NGO priorities for EP Plenary vote on the Baltic MAP

A group of NGOs collaborating on implementation of the CFP and supporting a new management plan for the Baltic Sea Fisheries that meets the ambition of the new CFP. This statement was sent to MEPs in EP prior to the vote in April 2015 on the Baltic Multiannual Plan file (2014/0285(COD) in plenary. The statement shows support of the agreed report from the PECH fisheries expert Committee and urges MEPs to make sure the plan matches the CFP.

NGO Priorities on the Baltic MAP for EP Plenary

April 1, 2015

Letter to EU Fisheries Ministers

A statement letter to the EU Fisheries Ministers from Coalition Clean Baltic, BirdLife Europe and Central Asia, Client Earth, Oceana, Seas at Risk, The Fisheries Secretariat, The Pew Charitable Trusts, and WWF Poland.
Read the letter

March 26, 2015

Key NGO priorities for the Baltic Multi-Annual Plan to European Parliament

This is a statement with recommendations from a joint group of NGOs directly addressing the Baltic MAP proposal report and amendments given to the PECH Committe in EP, March 2015. 20150326 NGO priorities Baltic MAP_final

February 28, 2015

NGO briefing for BALTFISH on the MAP

NGO considerations for BALTFISH members on the Multiannual plan for the main Baltic Fisheries.
Read the briefing here

January 22, 2015

Joint NGO priorities on the multiannual plan for the Baltic Sea

This is a joint statement on key priorities to address in creation of the new multiannual fisheries management plan for the sprat, herring and cod stocks in the Baltic Sea.possibilities_for_baltic_sea_fisheries It is a joint statement including CCB, Birdlife, Oceana, WWF, FISH and FANC and it has been shared with Member States and European Parliament members as well as internally in NGOs. Read the statement here: Jan2015 Joint NGO Priorities on the Baltic Sea Multiannual Plan_FINAL


August 1, 2014

Priorities for environmentally responsible aquaculture in the EU

A joint NGO position paper by  Coalition Clean Baltic (CCB), Seas At Risk (SAR), BirdLife Europe, World Wide Fund for Nature (WWF), The Fisheries Secretariat (FISH), Marine Conservation Society (MCS), European Bureau for Conservation and Development (EBCD), Swedish Society for Nature Conservation, North Sea Foundation, Friends of the Earth, Germany (BUND), ENT Foundation.

February 28, 2014

Joint NGO response from CCB, FISH, FANC and Oceana on Landing Obligation

CCB, Fishereis Secretariat, Oceana, FANC and WWF made a joint response to a draft discard plan presented by the BALTFISH group. The original text and the NGO statement is available here:
Joint NGO statement
BALTFISH original proposal


Statements 2002–2013